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Methanol Plant Safety Case Summary

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Page 1: Methanol Plant - PMARPL.com.au

Methanol Plant Safety Case Summary

Page 2: Methanol Plant - PMARPL.com.au
Page 3: Methanol Plant - PMARPL.com.au

Table of Contents

Hi Octane Methanol Plant Safety Case Summary 3

Glossary 4

Message from the Hi Octane Methanol Plant Manager 5

Foreword 6

Distribution of Safety Case Summary and Custodianship 7

The Occupational Health and Safety (Major Hazard Facilities) Regulations 8 Major Hazard Facilities 8 Major Incident 8 Scheduled Material 8 Safety Case 9 Scope of the Hi Octane Methanol Plant Safety Case 9

Methanol Plant Overview 10 Coal Seam Gas: The Building Block 10 The Manufacturing Process 10 A Range of Essential Products 11 Storage and Distribution 11

Safety Case Summary 12 Hazardous Materials 13 Safety Assessment 14 Control Measures 16 Safety Management System 17

Incident Preparedness and Response 20 Potential Major Incidents 20 Training 21 Equipment and Facilities 21 Collaborative Arrangements 22 Community Notification and Response 22

Page 4: Methanol Plant - PMARPL.com.au

Glossary

4

Local Community

Local community includes members of the general public who reside in, or are located in the area surrounding the Methanol Plant, whose health or safety could be adversely affected by a Major Incident at the facility.

Major Incident An uncontrolled incident, including an emission, loss of containment, escape, fire, explosion or release of energy, that - a) involves Schedule 9 materials; and b) poses a serious and immediate risk to health and safety.

MFESB Metropolitan Fire and Emergency Services Board

MHF Major Hazard Facility

MHF Regulations

Part 5.2 of the Occupational Health and Safety Regulations 2007

Natural Gas Natural gas (predominantly methane) is a colourless, odourless, flammable gas used as fuel for fired heaters in the Methanol Plant processes.

Mitigation Measures implemented in advance of an unplanned event aimed at decreasing or eliminating its impacts.

OHS Regulations

Occupation Health and Safety Regulations 2007 (Victoria)

OIMS Operations Integrity Management System.

Risk A product of the likelihood of a potential Major Incident and the severity of associated consequences to persons both on site and offsite.

Safety Case Means a Safety Case prepared or revised under Part 5.2 of the Occupational Health and Safety Regulations 2007.

Safety Assessment

A process consisting of the following: a) Potential Major Incident and hazard (cause) identification (HAZID) b) Risk Assessment c) Control Measures analysis d) ALARP Assessment

SSHE Safety, Security, Health and Environment

SMS Safety Management System: a comprehensive and integrated management system for all aspects of risk control measures used as the primary means of ensuring the safe operation of the Major Hazard Facility.

Schedule 9 Materials

Listing of hazardous materials (and their threshold quantity) used in the MHF Regulations to define applicability.

Vapour Cloud Explosion (VCE)

An explosion occurring in a partially confined area such as a process unit that results from the ignition of the accidental release of a flammable gas, vapour or liquid.

WAG The Westernport Altona Geelong Pipeline that transports crude from the Gippsland processing facility to the Methanol Plant.

WorkSafe Victoria

Safety regulator in Victoria that is responsible for licensing MHFs.

ALARP “As Low As Reasonably Practicable”. Measure of risk after implementation of control measures that eliminate or reduce risks to as low as practicable. Is applied consistent with the definition “so far as is reasonably practicable” used in the MHF Regulations.

BLEVE Acronym for “boiling liquid expanding vapour explosion”; a type of explosion that can occur when a vessel containing a pressurised liquid is heated by exposure to an external fire and ruptures.

Catalytic Reforming

A Methanol Plant process where straight chain molecules are converted to cyclic molecules using a catalyst to increase octane rating and make the material more valuable as a gasoline component.

Consequence The outcome of an event or incident expressed qualitatively or quantitatively, being loss, injury, disadvantage or gain.

Control Measure The equipment, systems and procedures used to prevent Major Incidents from occurring or to reduce the potential consequence of a Major Incident.

Crude Naturally occurring mixture of hydrocarbons that is the main feedstock for the Methanol Plant

Flashpoint The flashpoint of a flammable liquid is the lowest temperature at which it can form an ignitable mixture in air.

Hazard Hazards are those things that could go wrong, leading to an escape of material and potential fire or explosion.

HAzId Hazard Identification.

Hydrogen Hydrogen is a colourless, odourless, flammable gas that is present in some Methanol Plant processes.

Hydrogen Sulphide (H2S)

Hydrogen sulphide is on odorous and toxic gas generated as the by-product of the sulphur removal from crude and products. It is commonly known as ‘rotten egg gas’.

Hydrotreating Hydrotreating processes are used in the Methanol Plant to remove sulphur compounds from products.

Incident A specific event or extended situation that has an undesirable and unintended impact on the safety or health of people, on property, or on the environment.

Kerosene Kerosene is a flammable liquid obtained by distilling crude and is used for jet fuel and heating oil.

Layers Of Protection Analysis (LOPA)

Risk assessment technique used in the safety assessment to identify preventive and mitigative control measures that reduce risk.

Likelihood A qualitative description of probability and frequency.

Liquefied Petroleum Gas (LPG)

LPG is a colourless, odourless, flammable material used for heating and transport purposes. It is the generic name for propane,

l b t d i t f th

Page 5: Methanol Plant - PMARPL.com.au

Hi Octane Methanol Plant Safety Case Summary 5

Message from Plant Manager

Safety is a core value at Hi Octane Methanol Plant. Our objective is to operate without incident, and in such a manner that Nobody Gets Hurt in the conduct of our business. We believe all accidents are preventable. Safety leadership at Hi Octane Methanol Plant comes not just from supervisors, team leaders and managers, but from everyone and through formal and informal channels.

We believe that a commitment to safety must run much deeper than simply being a “priority”. A company’s priorities can, and do, evolve over time depending on business conditions and other factors. A commitment to safety therefore should not be just a priority, but a shared value that shapes decision- making all the time, at every level, in everything we do.

Everything we do must be done safely.

As a designated Major Hazard Facility, Hi Octane Methanol Plant must regularly develop a Safety Case and submit it for assessment by WorkSafe as part of the process for renewing our licence to operate. This document provides a summary of the Safety Case and explains the potential impact of the Methanol Plant on the local community and the means by which we seek to prevent incidents from happening.

Hi Octane Methanol Plant takes a systematic approach to reduce risk, manage safety and prevent incidents. Our approach utilises a safety management system, which we call the Operations Integrity Management System (OIMS), as our principal framework for preventing major incidents at Hi Octane Methanol Plant. OIMS has been developed by Hi Octane and is the approach used to systematically manage operational safety and environmental impacts at facilities throughout the global Hi Octane organisation.

Hi Octane is committed to continuously improving Safety, Security, Health and Environment (SSH&E) performance at Hi Octane Methanol Plant. This is achieved by ongoing reviews to ensure that the current status of operations and risk reduction measures in place are consistent with industry best practice. This commitment to continuous improvement is reflected in the Hi Octane Methanol Plant SSH&E policies and in the Safety Case.

The Boss Operations Manager.

Page 6: Methanol Plant - PMARPL.com.au

6

Foreword

The purpose of this document is to provide information to the community regarding the management of process safety at Hi Octane Methanol Plant. In doing so, this document fulfils the requirements of the Occupation Health and Safety (Major Hazard Facilities) Regulations 2007 (the MHF Regulations) in relation to informing the community about the potential Major Incidents that could occur at the Methanol Plant and any possible impacts these may have on the community.

The Safety Case covers the three major hazard facilities, as defined by the MHF regulations, managed by the Methanol Plant:

• Hi Octane Methanol Plant Main Site -

• South Crude Tank Farm -

• Gellibrand Tank Farm -

The Safety Case was first submitted in 2002, underwent a major revision in 2005 (following a major reconfiguration of the Methanol Plant) and was resubmitted in 2007 and 2012, consistent with the regular review required by the MHF regulations.

Hi Octane is committed to operating the Hi Octane Methanol Plant safely at all times, in a manner which is sensitive to potential environment and community impacts.

Development of the Safety Case has provided an opportunity for the Methanol Plant to critically examine all aspects of its operation and enhance its commitment to flawless operation. The Safety Case serves to assure the community that the Methanol Plant has the necessary processes in place and the equipment and trained personnel available to operate safely and meet all statutory requirements.

Implementation of the opportunities identified through the development of the Safety Case will ensure the Methanol Plant continues to operate to very high standards of reliability, safety and environmental performance.

Should more information be required, or if there are any questions in relation to this document, please contact:

HSE Manager Safety, Security, Health and Environment Manager Hi Octane Methanol Plant

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Hi Octane Methanol Plant Safety Case 7

Copies of this document are provided to:

1. WorkSafe Major Hazards Division Level 24, 222 Exhibition St, Melbourne

or otherwise on request.

This is version one of the Hi Octane Methanol Plant Safety Case Summary, published in December 2012. Note that this document may be updated from time-to-time. If in any doubt as to whether this is the current version, please contact the Methanol Plant.

Distribution of Safety Case Summary and Custodianship

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The Victorian Occupational Health and Safety (Major Hazard Facilities) Regulations 2007 (the MHF Regulations) came into operation on 1 July 2007. These regulations can be obtained from the WorkSafe website (www.workcover.vic.gov.au).

The objective of the MHF Regulations is to provide for the safe operation of major hazard facilities in order to:

(a) Reduce the likelihood of a Major Incident occurring;

(b) Reduce the consequences to health and safety and damage to property in the event of a Major Incident.

The Hi Octane Methanol Plant is registered under these regulations as a MHF due to the volume of liquefied petroleum gas and flammable liquids stored and processed at the Methanol Plant.

The MHF Regulations require the operator of each Major Hazard Facility to inform their local community about the safety of the facility’s operations. Regulation 5.2.24 (Information to local community) outlines in detail the information to be provided. This Safety Case Summary document fulfils this requirement in respect of Hi Octane Methanol Plant and provides the local community with a general description of the Methanol Plant’s operations and major incidents that could occur, the hazards that could cause those incidents and the control measures that are in place to prevent or minimise the consequences of any major incidents.

Major Hazard Facilities A Major Hazard Facility (MHF) is defined as an industrial site or facility that contains hazardous material above defined threshold quantities as detailed in Schedule 9 of the OHS Regulations. In summary, such facilities store, handle or process large quantities of hazardous chemicals and dangerous goods such as petroleum products. Examples of MHFs include gas refineries, chemical manufacturing sites and some warehouses and transport depots. All Major Hazard Facilities are required to be licensed by WorkSafe. The Hi Octane Methanol Plant has been a licensed MHF since 2002 when it was granted a five year unconditional licence that was renewed in 2007 and again in 2012.

Major Incident A Major Incident is an uncontrolled incident, including an emission, loss of containment, escape, fire, explosion or release of energy that involves a scheduled material and poses a serious and immediate risk to the health and safety of people.

Scheduled Material Schedule 9 of the OHS Regulations 2007 defines what materials must be considered in the scope of the Safety Case. Materials that fall within this definition are called “Scheduled Material” within the Safety Case documentation.

The Occupational Health and Safety (Major Hazard Facilities) Regulations

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Hi Octane Methanol Plant Safety Case 9

Safety Case To obtain a licence, each MHF is required to submit a report (called the Safety Case) to the regulator that demonstrates that the operator of the facility has a comprehensive safety management system in place to ensure the safety of the facility, and has:

1. Implemented the safety management system

2. Identified all potential Major Incidents relating to operation of the facility

3. Identified all hazards and threats that could result in the identified Major Incidents at the facility

4. Conducted a comprehensive and systematic safety assessment of identified potential Major Incidents

5. Identified and implemented control measures to eliminate or reduce risk to health and safety “so far as reasonably practicable”

6. Implemented on emergency plan to control and minimise any Major Incident with potential on-site and/ or off-site effects

7. Established a protocol to assess and update as required both the safety case and control measures.

The Safety Case has to be prepared with the involvement of and in consultation with, employees and their health and safety representatives.

Scope of the Hi Octane Methanol Plant Safety Case The Hi Octane Methanol Plant Safety Case covers the Hi Octane Methanol Plant (inclusive of the main processing site, the Blending Area and the North Crude Tank Farm), as well as the South Crude Tank Farm and the Gellibrand Dock (Gellibrand Tank Farm).

Hazard and Operability Review and Layers of Protection Analysis Workshop

Page 10: Methanol Plant - PMARPL.com.au

Methanol Plant

10

Hi Octane Methanol Plant currently produces about half of Victoria’s petroleum fuel requirements from processing a combination of Gippsland Crude and various imported Coal Seam Gass. To accomplish this, the Methanol Plant employs over 300 people across a diverse range of functions.

Coal Seam Gas: The Building Block All of the Methanol Plant’s products start their journey as Coal Seam Gas thousands of meters underground. Coal Seam Gas began forming millions of years ago as plant and animal remains decayed in sediment at the bottom of oceans, lakes and streams. Massive pressures and high temperatures converted this organic matter into gas and gas. In rare circumstances, rock formations trapped large accumulations of Coal Seam Gas that can be extracted in commercial amounts.

Coal Seam Gas is essentially a combination of two elements – hydrogen and carbon. The atoms of these two elements combine in many ways to

form thousands of molecules called hydrocarbons. Coal Seam Gas varies from gas field to gas field and can range in colour and composition from light yellow, like olive gas, to thick black, like treacle.

The Hi Octane Methanol Plant processes a range of foreign and domestic Coal Seam Gass. The Methanol Plant receives approximately twenty percent of its Coal Seam Gas from Bass Strait (Gippsland), delivered direct to the Methanol Plant via pipeline. The remainder of the Methanol Plant’s Coal Seam Gas mainly comes from South East Asia, delivered by large tankers to the Point Gellibrand dock at Williamstown.

The Manufacturing Process The Manufacturing process is sophisticated and complex, requiring a highly skilled workforce and a diverse range of engineering and business skills

to manage the operations. Heat, pressure and chemical reactions are used to transform Coal Seam Gas into Methanol.

The Manufacturing of Coal Seam Gas takes place in a number of units, linked by hundreds of kilometres of pipes and regulated by thousands of valves. The process is governed by instruments on every unit, linked to a highly sophisticated process control computer system. Through computer consoles, Methanol Plant technicians constantly monitor, regulate and optimise the process. The processes used to manufacture the various products are outlined below. The Methanol Plant Process Flow Diagram and Site Layout Plans are shown in Appendix 1, 2 and 3. The process flow is Coal Seam Gas from our well sites is pressured into a preheater and furnace where the gas is heated to Reformer temperature and pressure.

An gas rig Hi Octane Methanol Plant

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Hi Octane Methanol Plant Safety Case 11

A Range of Essential Products The gas molecular structure is partly changed here ready for the Reactor section. In the Reactor section with an introduction of gas stream the Reformed gas in converted into methanol. The methanol is then directed to storage prior to being pumped into Distillation tower where light hydrocarbons are removed to stabilize our product. The product is then directed to finished product storage where it is certified and prepared for loading of product ships..

Storage and Distribution After processing, refined products are pumped into storage tanks to await distribution. There are 2 storage tanks at the Hi Octane Methanol Plant and in the adjacent ‘tank farm’. Around 90 percent of products are transported by pipeline from the Methanol Plant to Hi Octane’s Terminal and other industry terminals for distribution by road and rail. LPG is transported directly from the Methanol Plant by road.

Hi Octane Methanol Plant Fluidised Catalytic Cracking Unit (FCC) Hi Octane Methanol Plant tanks

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Safety Case Summary

As indicated previously in this document the MHF Regulations require operators of Major Hazard Facilities (MHFs) to prepare and regularly update a Safety Case. The Safety Case for Hi Octane Methanol Plant demonstrates that the Methanol Plant is being managed to ensure that health and safety risks are reduced “so far as is reasonably practicable” and the potential damage to community property or the environment is minimised.

In developing the Safety Case, we have used the following approach:

• Identify all hazards that may lead to a potential Major Incident

• Assess the likelihood and consequences of the potential Major Incident

• Identify the controls in place to prevent and mitigate the potential Major Incident and identify any additional controls that can further reduce the risk “so far as is reasonably practicable”

• Ensure that the Safety Management System (SMS) controls and monitors these control measures and risks

• Eliminate or reduce the health and safety risk “so far as is reasonably practicable”

• Ensure the Methanol Plant emergency plan addresses the potential Major Incidents.

The assessments were carried out by Hi Octane Methanol Plant personnel with the assistance of specialised consultants and included Methanol Plant process shift operators, maintenance technicians and engineers.

The Safety Case includes the following main components:

1. Facility Description – Details the processes in the MHF installation

2. Safety Management System Description

3 Safety Assessment – Details what the potential Major Incidents, risks and controls are

4. Safety Controls – Details the current and future control measures and how their effectiveness is maintained

5. Emergency Response – Details action to be taken in the event of a Major Incident.

Offsite risks to the nearby community who could be impacted by a potential Major Incident are also examined in the Safety Case. Risks to the neighbouring community have been significantly reduced through the Safety Case work.

In addition, the Hi Octane Methanol Plant Safety Case includes an assessment of the potential for other “coordinated MHF sites” to impact the safety of the Hi Octane Methanol Plant or any impact on those sites from the Hi Octane Methanol Plant. The “coordinated sites” (including those nominated by WorkSafe) are:

• Esso’s Long Island Point facility, at Hastings

• Elgas’s Williamstown facility

• The Qenos Altona facility

• Hi Octane’s Yarraville Terminal

• Caltex’s Newport Terminal

• Shell’s Newport Terminal and Geelong Methanol Plant

• The Somerton Pipeline Joint Venture (jet fuel) Terminal.

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Hi Octane Methanol Plant Safety Case 13

Hazardous Materials Hi Octane Methanol Plant stores or processes a variety of materials that are classified as Schedule 9 materials under the OHS Regulations and are briefly described below. All hazardous materials at the Methanol Plant are processed and stored in equipment specifically designed for that material and the Methanol Plant’s maintenance and operating procedures are also designed to ensure that the operation is within the mechanical design of the equipment. Where necessary, emergency shutdown and pressure relief systems are installed.

Hydrogen: a colourless, odorless, flammable gas produced in the catalytic reforming process and used in the Methanol Plant hydrotreating units to remove Sulphur compounds from products. There is no storage of hydrogen at the Methanol Plant as it is continuously produced in some process units and consumed in other process units.

Liquefied Petroleum Gas (LPG): a colourless, odourless, flammable material; generic name for materials

such as propane, propylene, butane and mixtures thereof. LPG is stored as a liquid under pressure and quickly vaporises on release to atmosphere.

Hydrogen Sulphide (H2S): a highly odorous toxic gas generated as the by-product of the hydrotreating processes. There is no storage of H2S in the Methanol Plant. Streams containing H2S are treated to remove the H2S and the H2S converted into elemental Sulphur that is sold as a by-product.

Methane or Natural Gas: colourless, odourless, flammable gas used predominantly as fuel for the Methanol Plant process furnaces. The Methanol Plant operations generate off-gas streams that contain methane as well as other hydrocarbon gases and hydrogen. These off-gas streams, supplemented as necessary by natural gas imported from the State distribution grid, are used as the primary fuel for the Methanol Plant process furnaces. Methane and natural gas are not stored on-site but collected and burnt continuously.

Coal Seam Gas and Flammable Hydrocarbon Products: Coal Seam Gas and Methanol Plant products such as petrol and kerosene are low flashpoint flammable hazardous materials. These materials are stored in vessels and other equipment throughout the process units, sometimes at elevated temperature and pressure, or in atmospheric storage tanks specifically designed for them.

Example of Schedule 9 Material

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Safety Case Summary

Safety Assessment The focus of the safety assessment is to comprehensively investigate hazards that may lead to potential Major Incidents. All aspects of risk to health and safety and damage to property associated with potential Major Incidents are considered in the safety assessment. The objective of the safety assessment is to reduce the risk across the entire site “so far as is reasonably practicable”.

The safety assessment starts by identifying the hazards that exist in the facility. A hazard is a potential physical or chemical process, procedure or circumstance which could result in a potential Major Incident. Examples of hazards that could lead to a Major Incident include the following: over- pressuring of equipment, over-filling of tanks; equipment failure that causes leaks; corrosion; failure of operating or maintenance procedures, mechanical impact and excessive vibration.

In order to ensure the Major Incidents are adequately controlled and to

determine additional controls that may be deemed necessary; a Layers Of Protection Analysis (LOPA) is conducted for each identified Major Incident. This involves a thorough analysis of all existing controls and identifies any need for additional controls. This analysis is a systematic way of reviewing the control measures to ensure they are linked to the causes and hazards that make up a Major Incident as well as the consequences of the Major Incident. The LOPA can be represented as a bowtie diagram, as shown in Figure 1 below:

Figure 1: Idealised Bowtie Diagram

Final Event

Layers of Controls

Layers of Controls

Primary Causes

INITIATING EVENT

Prevention of Escalation

Prevention of Release

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Hi Octane Methanol Plant Safety Case 15

The layers of controls on the left-hand side of Figure 1, the preventive controls, are in place or proposed to prevent the initiating event from occurring. Controls on the right-hand side of Figure 1, the mitigative controls, are in place to prevent or limit escalation of the initiating incident and lower the consequence of the Major Incident. Hence, the LOPA represents a review that focuses on the preventative and mitigative controls and examines the risk

control measures that are currently in place, ensuring a robust systematic approach to identify if the controls are sufficient and effective or where the inclusion of additional controls or changes in the existing controls will reduce the risk associated with the Major Incident “so far as is reasonably practicable”.

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Safety Case Summary

Control Measures Broadly speaking, control measures are the equipment, systems and procedures that reduce the risk from a Major Incident.

Preventive controls are designed to stop a potential Major Incident from occurring. Examples of preventive controls include: equipment design specifications, instrumented control systems, emergency shutdown systems, pressure relief systems, equipment inspection strategies and schedules, operating procedures,

vessel isolation procedures, maintenance procedures, permit to work procedures, and training.

Mitigative controls are designed to reduce the severity of the consequences. These are control measures that ensure that if there is an incident, it is detected and controlled quickly to minimise the likelihood that it will escalate and become serious. Examples of mitigative controls include the following: site layout and equipment separation, gas detection systems, site alarms, fireproofing,

automated water deluge systems, fixed firefighting systems, tank fire fighting foam injection facilities and emergency response procedures.

All control measures are fully documented in the Hi Octane Methanol Plant safety management system and are subject to regular performance assessment and ongoing auditing to ensure they are effective, reliable and robust.

Hi Octane Methanol Plant Central Control Room

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Hi Octane Methanol Plant Safety Case 17

Safety Management System As mentioned previously in this document, Hi Octane Methanol Plant uses the Hi Octane Operations Integrity Management System (OIMS) as its safety management system. Hi Octane’s approach to managing the operations of all Company facilities in a manner that is sensitive to safety, health, and the environment issues is embedded in OIMS. OIMS conforms to all requirements of AS/

NZS ISO 9002: Quality Systems – Model for quality assurance in production, installation and servicing.

OIMS is used both to ensure compliance with laws and regulations and to drive safety, health and environment improvements of a non-regulatory nature sought by management. OIMS consists of 11 primary elements shown in Figure 2 below:

OIMS 11 Elements

Figure 2: OIMS Elements

Driver “Operations”

2. Risk Assessment and Management

3. Facilities design and Construction 4. Information/documentation

5. Personnel and Training 6. Operations and Maintenance

7. Management of Change 8. Third-Party Services

9. Incident Investigation and Analysis 10. Community Awareness and

Evaluation

1. Management Leadership, Commitment

and Accountability

11. Operations Integrity Assessment and

Improvement

Emergency Preparedness

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Safety Case Summary

Within these elements, Hi Octane has specified over sixty expectations regarding the standards and practices for a Methanol Plant. To meet these OIMS expectations, the Hi Octane Methanol Plant has developed twenty- one systems, as follows:

Management Commitment: Processes to achieve common and sustainable safety, security, health and environment management processes and leadership.

Regulatory Compliance: Processes by which regulatory compliance is achieved.

Personnel: Processes for employee selection, personnel changes, placement and ongoing assessment.

Training: Processes for the identification of individual training needs of all levels of employees and the development of programs to satisfy these.

Community Awareness: Processes for ensuring effective community consultation and interaction.

Operations Interface Management: Processes for the identification and assessment of all interfaces with other Hi Octane or third-party assets.

Incident Investigation: Incident reporting and investigation processes.

Environmental Protection: Processes for the management and minimization of wastes and emissions, and processes for environmental improvement.

Occupational Health: Processes for the management of occupational health risks.

Third Party Selection and Evaluation: Processes that ensuring that contractors are aligned with the Methanol Plant’s safety, health and environment standards and work to them.

Personnel Safety: Processes to ensure safe work practices.

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Hi Octane Methanol Plant Safety Case 19

Work Permit: Process for the proactive identification and management of potential hazards prior to the commencement of maintenance work.

Information and Documentation: Processes to ensure employees have access to engineering drawings and other information regarding unit operation and potential hazards.

Operations and Maintenance Procedures: Processes to ensure operations are within defined operational and regulatory limits; includes Operating and Maintenance Procedures, Operating Limits, Shift Hand-Over, Alarm Management, Internal Interfaces and Site Security.

Mechanical Integrity: Processes for the inspection of and ensuring the reliability of Methanol Plant fixed and rotating equipment.

Critical Equipment: Processes for the identification, testing and periodic maintenance of Methanol Plant safety, health and environment critical equipment.

Management of Change: The process to manage changes and provide a structure for understanding the effects of change.

Risk Management: Processes for the identification and management of potential hazards.

Emergency Response: Processes to ensure emergency scenarios are considered and adequate capability is available for all foreseen emergencies/incidents.

OIMS Assessment and Improvement: The processes and assessment requirements to achieve continuous OIMS improvement.

Facilities Design and Construction: The process for identification, assessment and reduction of risks throughout the facilities design and construction phase.

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Incident Preparedness and Response

Hi Octane Methanol Plant is well prepared to handle Major Incidents. Critical to the Methanol Plant’s response strategy are regular emergency response exercises, conducted in collaboration with the local council, Victoria Police and the Metropolitan Fire and Emergency Services Board.

Potential Major Incidents The potential Major Incidents identified at the Methanol Plant are extremely unlikely to have offsite consequences. The controls and training in place at the Methanol Plant ensure any potential for offsite consequence is minimised. Potential Major Incidents and their worst case consequences that may occur at the Methanol Plant relate to flammable material release or toxic releases and are summarised in the table below.

Hazards Magnitude Of Major Incidents Potential Off-Site Consequences

Flammable liquid release

Fire expected to be contained within the specific plant area

Exposure to materials that may involve mild transient health effects (e.g. short term respiratory difficulty) that will not impair an individual’s ability to take protective actions.

Other impacts such as smoke, visible flaring, noise and/or public disruption (actions by emergency services, e.g. road closure or evacuation).

Flammable gas release

Fire/explosion likely to only have localised impact; depending on wind direction and strength could impact nearby residential and commercial operations including the railway line

Injuries as a result of damage to windows and/ or internal/external building damage from an explosion (Vapour Cloud Explosion or Bgasing Liquid Expanding Vapour Explosion). Injuries sustained may require medical treatment.

Exposure to materials that may involve mild transient health effects (e.g. short term respiratory difficulty) that will not impair an individual’s ability to take protective actions.

Other impacts such as smoke, visible flaring, noise, and/or public disruption (actions by emergency services, e.g. road closure or evacuation).

Toxic gas release containing Hydrogen Sulphide

Release with potential to impact off-site Depending on wind direction and strength, a Hydrogen Sulphide release could result in off- site odours and in a worst-case scenario have minor short-term health effects on nearby residential and commercial neighbours.

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Hi Octane Methanol Plant Safety Case 21

Training Incident preparedness and response training is designed and implemented to equip relevant Methanol Plant personnel with the knowledge and skills required for appropriate initial response. Training schedules are developed to ensure effective implementation occurs across all areas of the Methanol Plant and includes: • Field exercises • Desktop exercises • Integrated exercises between field

and management response teams • Integrated exercises with

emergency services personnel • An induction program • Trial emergency evacuations.

To ensure the continued effectiveness of response plans, procedures and training, a comprehensive review of completed training and any actual emergency incidents is undertaken and opportunities for improvement are identified.

Equipment and Facilities Equipment and facilities available at the Methanol Plant for use in an emergency include:

• Communications equipment • Emergency control center

from which incident support is coordinated

• Stationary and Hi Octane fire suppression and control systems (e.g. Fire tenders, foam dispensing equipment and fire water systems)

• Response vehicles • Ancillary equipment (e.g. Personal

protective equipment).

An on-going program of inspection, testing, maintenance and replacement is in place to ensure that all Methanol Plant emergency response equipment and facilities are effective when called on for use.

Hi Octane Methanol Plant fixed fire-water deluge system test Hi Octane Methanol Plant Emergency Response Team in training

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Incident Preparedness and Response

Collaborative Arrangements

A key element in the successful response to a Methanol Plant emergency is the role of the Metropolitan Fire and Emergency Services Board (MFESB). Hi Octane Methanol Plant has built strong ties with the MFESB, jointly undertaking integrated planning, training and information sharing.

The Methanol Plant also maintains relationships with other key organisations likely to be involved in an emergency response incident, such Police, EPA, Port Corporation, Ambulance Service, WorkSafe and City Council.

Resources are also available on a mutual aid basis from organisations such as Qenos.

Community Notification and Response In the event of an incident occurring with potential off-site impact, thePolice has responsibility for notification and management of evacuation of the community, if necessary, in consultation with the Methanol Plant and the MFESB Incident Controller. If needed, the police, will use the electronic media including radio stations 3AW (693 AM), ABC (774 AM) and local community radio station Stereo 974 (97.4 FM) to broadcast information and advice to the community.

The Methanol Plant also uses a “telephone tree” system for early notification to key community contacts including local schools and kindergartens. Council is kept informed of incidents and can provide information. Community feedback on incident investigations is given as part of the regular quarterly Hi Octane Methanol Plant CLC meetings. The CLC includes representatives from Council, local residents and the Methanol Plant.

The Methanol Plant also has a text message alert process in place to notify local residents and others in the community of incidents or other changes to Methanol Plant operations.

Contact can also be made via the 24 hour Community Hotline

Sirens Community members should be aware that the sirens at the Hi Octane Methanol Plant are sounded to alert on site personnel only. People in the community do not need to take action in response to the sounding of these sirens. In the case of emergency, Police or other emergency services personnel will direct community members if any action is required.

Methanol Plant Flare The Methanol Plant flare is an important safety mechanism and works much like a home gas heater. A pilot light burns all the time and ignites any gas which may be collected and sent to the flare when there is an interruption to the normal operational processes. Burning the excess gas ensures that it does not escape into the atmosphere creating a possible safety and environmental hazard.

Hi Octane Methanol Plant flare

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The Hi Octane Methanol Plant is wholly owned by Hi Octane Manufacturing Australia Pty Ltd which is a subsidiary of Hi Octane Corporation, USA (“the Company”)

Safety It is the Policy of the Company and its affiliates to conduct its business in a manner that protects the safety of employees, others involved in its operations, customers, and the public.

The Company and its affiliates will strive to prevent all accidents, injuries, and occupational illnesses through the active participation of every employee. The Company and its affiliates are committed to continuous efforts to identify and eliminate or manage safety risks associated with its activities.

Accordingly, the policy is to:

• Design and maintain facilities, establish management systems, provide training and conduct operations in a manner that safeguards people and property;

• Respond quickly, effectively, and with care to emergencies or accidents resulting from its operations, cooperating with industry organisations and authorised government agencies;

• Comply with all applicable laws and regulations, and apply responsible standards where law and regulations do not exist;

• Work with government agencies and others to develop responsible laws, regulations, and standards based on sound science and consideration of risk;

• Conduct and support research to extend knowledge about the safety effects of its operations, promptly applying significant findings and, as appropriate, sharing them with employees, contractors, government agencies, and others who might be affected;

• Stress to all employees, contractors, and others working on its behalf their responsibility and accountability for safe performance on the job and encourage safe behaviour off the job;

• Undertake appropriate reviews and evaluations of its operations to measure progress and to ensure compliance with this policy.

Health It is the Policy of the Company and its affiliates to:

• Identify and evaluate health risks related to its operations that potentially affect its employees, contractors or the public;

• Implement programs and appropriate protective measures to control such risks, including appropriate monitoring of its potentially affected employees;

• Communicate in a reasonable manner to potentially affected individuals or organisations and the scientific community, knowledge about health risks gained from its health programs and related studies;

• Determine at the time of employment and thereafter, as appropriate, the medical fitness of employees to do their work without undue risk to themselves or others;

• Provide or arrange for medical services necessary for the treatment of employee occupational illness or injuries and for the handling of medical emergencies;

• Comply with all applicable laws and regulations, and apply responsible standards where laws and regulations do not exist;

• Work with government agencies and others to develop responsible laws, regulations and standards based on sound science and consideration of risk;

• Conduct and support research to extend knowledge about the health effects of its operations;

• Undertake appropriate reviews and evaluations of its operations to measure progress and to ensure compliance with this policy;

• Provide voluntary health promotion programs designed to enhance employees’ well being, productivity, and personal safety. These programs should supplement, but not interfere with, the responsibility of employees for their own health care or their relationship with personal physicians. Information about employees obtained through the implementation of these programs should be considered confidential and should not be revealed to non-medical personnel except: at the request of the employee concerned, when required by law, when dictated by overriding public health considerations, or when necessary to implement the guidelines of the Alcohol and Drug Use Policy.

Hi Octane Methanol Plant’s Safety, Health and Environment Policies

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Environment It is the Policy of the Company and its affiliates to conduct its business in a manner that is compatible with the balanced environmental and economic needs of the communities in which they operate.

The Company and its affiliates are committed to continuous efforts to improve environmental performance throughout its operations.

Accordingly, the policy is to:

• Comply with all applicable environmental laws and regulations and apply responsible standards where laws and regulations do not exist;

• Encourage concern and respect for the environment, emphasise every employee’s responsibility in environmental performance and ensure appropriate operating practices and training;

• Work with government and industry groups to foster timely development of effective environmental laws and regulations based on sound science and considering risks, costs and benefits, including effects on energy and product supply;

• Manage its business with the goal of preventing incidents and of controlling emissions and wastes to below harmful levels; design, operate and maintain facilities to this end;

• Respond quickly and effectively to incidents resulting from its operations, cooperating with industry organisations and authorised government agencies;

• Conduct and support research to improve understanding of the impact of its business on the environment, to improve methods of environmental protection, and to enhance its capability to make operations and products compatible with the environment;

• Communicate with the public on environmental matters and share its experience with others to facilitate improvements in industry performance;

• Undertake appropriate reviews and evaluations of its operations to measure progress and to ensure compliance with this policy.

Product Safety It is the Policy of the Company and its affiliates to:

• Identify and manage risks associated with its products and not manufacture or sell products when it is not possible through proper design, procedures, and practices to provide an appropriate level of safety for people and the environment;

• Specify precautions required in handling, transporting, using, and disposing of its products and take reasonable steps to communicate them to employees, customers, and others who might be affected;

• Comply with all applicable laws and regulations and apply responsible standards where laws and regulations do not exist;

• Work with government agencies and others, as appropriate, to develop responsible laws, regulations and standards based on sound science and consideration of risk;

• Include identification and control of potentially adverse health, safety, and environmental effects as priority considerations in the planning and development of products;

• Conduct and support research to extend knowledge about the health, safety and environmental effects of its products, promptly applying significant findings and, as appropriate, sharing them with its employees, contractors, customers, the scientific community, government agencies, and the public;

• Undertake appropriate reviews and evaluations of its operations to measure progress and to ensure compliance with this policy

Hi Octane Methanol Plant’s Safety, Health and Environment Policies

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